§ 17 Risk analyses and emergency preparedness assessments
The responsible party shall carry out risk analyses that provide a balanced and most comprehensive possible picture of the risk associated with the activities. The analyses shall be appropriate as regards providing support for decisions related to the upcoming processes, operations or phases. Risk analyses shall be carried out to identify and assess what can contribute to, i.e., major accident risk and environmental risk associated with acute pollution, as well as ascertain the effects various processes, operations and modifications will have on major accident and environmental risk.
Necessary assessments shall be carried out of sensitivity and uncertainty.
The risk analyses shall
- identify hazard and accident situations,
- identify initiating incidents and ascertain the causes of such incidents,
- analyse accident sequences and potential consequences, and
- identify and analyse risk-reducing measures, cf. Section 11 of the Framework Regulations and Sections 4 and 5 of these regulations.
Risk analyses shall be carried out and form part of the basis for making decisions when e.g.:
- identifying the need for and function of necessary barriers, cf. Sections 4 and 5,
- identifying specific performance requirements of barrier functions and barrier elements, including which accident loads are to be used as a basis for designing and operating the installation/facility, systems and/or equipment, cf. Section 5,
- designing and positioning areas,
- classifying systems and equipment, cf. Section 46 of the Activities Regulations,
- demonstrating that the main safety functions are safeguarded,
- stipulating operational conditions and restrictions,
- selecting defined hazard and accident situations.
For larger discharges of oil or condensate, simulations of drift and dispersion shall be carried out.
Emergency preparedness analyses shall be carried out and be part of the basis for making decisions when e.g.
- defining hazard and accident situations,
- stipulating performance requirements for the emergency preparedness,
- selecting and dimensioning emergency preparedness measures.
The environmental risk and emergency preparedness analyses shall be updated in case of significant changes affecting the environmental risk or the emergency preparedness situation. In any case, updating needs shall be assessed every five years. The assessment shall be documented and made available to the Norwegian Environment Agency on request.
Section last changed: 01 January 2018
The NORSOK Z-013 and ISO 31000 standards should be used, amongst others, to fulfil the requirements for risk analyses and emergency preparedness analyses. When performing risk analyses of maritime systems and of stability, the Norwegian Maritime Authority’s Regulations relating to risk analyses for mobile facilities (in Norwegian only) should be used in addition. For information, see also Section 5 of the Facilities Regulations.
The NORSOK N-003 standard, Chapter 8.3.2, can be used for analyses of ship collisions.
Offshore petroleum activities
Assessments of environmental risk associated with operational discharges should be performed according to Sections 60 and 64 of the Activities Regulations.
The purpose of an environmental risk analysis is to identify the environmental values exposed to a risk from a given activity and the magnitude of this. Further, the purpose is to use the results to identify needs for new or additional risk reducing measures.
For environmental risk and emergency preparedness analyses connected to acute pollution for offshore facilities, the following should be included:
- The operator shall perform analyses connected to acute pollution from their own facilities and activities. All facilities (wells, subsea templates, production platforms, pipelines) and activities in the field should be included in the analyses.
- In case of modifications and considerable changes, these shall be analysed in context to the existing facilities and activities, not as isolated facilities or activities, cf. Section 16 of the Management Regulations.
- To constitute a sufficient basis for the decision, as mentioned in the first subsection second sentence and Section 16 first subsection, the analyses should be performed for the entire year. This, inter alia, to minimise the risk, as mentioned in Section 11 of the Framework Regulations, by planning activities to the periods with the lowest risk and to consider changes in contingency requirements throughout the year. For activities with drilling time restrictions, the analyses should also include incidents starting up at a time where drilling is permitted, but with a duration exceeding this period.
- The analyses should include sea surface, water column, seafloor, coast and shoreline, ice edge and icy waters where this is relevant.
- The analyses shall be updated in case of changes as mentioned in Section 17, last subsection. Changes hereby defined as changes in an activity, input data, and/or tools and methods. The updates of the environmental risk and emergency preparedness analyses should include an assessment of whether the best available techniques have been applied to reduce the environmental risk. Documentation of the assessments performed should be available for the Norwegian Environment Agency upon request.
For input data (defined as data of environmental values, meteorological and oceanographic data and probability for discharge).
- The analyses should be based on hazard and accident situations as mentioned in third section item a) that could lead to acute pollution. The selected hazard and accident situations must be appropriate for the analyses to be performed. For the selection of hazard and accident situations, frequencies or probabilities for discharges based on relevant, updated statistics for historical incidents and evaluations of activity-specific conditions should be used. The data sources should be referred to. A distribution of rates and durations reflecting the diversity in possible magnitudes of a potential acute pollution should be presented. The longest duration of a blowout should be the time required for drilling a relief-well, including time for mobilising, magnetic searching and killing of a blowing well. Important assumptions and uncertainties in the calculations of rates and durations should be included.
- The analyses should be based on the best available meteorological and oceanographic data of wind, temperature and currents. The data should cover a longer period of time up to as close to current date as possible. Further, the data should have a high resolution both in time and space.
- The analyses shall be based on the type of pollution, including the oil type relevant for the activity. The physical, chemical and ecotoxicological properties of the pollution, including results from characterization of oil and condensate, according to Section 59 of the Activities Regulations, and real data for efficacy of contingency material, according Section 42 of the Facilities Regulations, should be included in the basis for the analysis. If the oil type is unknown, a suitable reference oil may be used. The selection of reference oil should be justified.
For simulations of drift and dispersion (large discharges of oil or condensate, as mentioned in the fifth subsection, is defined as blowout scenarios).
- Simulations of drift and dispersion should be performed for the selected hazard and accident situations using a statistical representative distribution of the different rates and durations. It should be described how this accounted for in the simulations. Simulations should be performed for the actual discharge location (surface/seafloor).
- Simulations should be performed for a sufficient number of start-up dates from the statistical wind- and current datasets in a way that the simulations give a representative picture of the different weather situations in the different seasons.
- The model should be able to treat oil drift in three dimensions, i.e. downmixing into- and spreading with the water masses, in addition to horizontal drift and spreading at the surface over time. In addition, the model should handle the oil’s physical and chemical properties and the oil’s weathering properties, i.e. evaporation, emulsification, dissolving in water, in addition to natural dispersion and biochemical decomposition in time and space.
- Effects of acute oil pollution on environmental values in the water column can be calculated based on detailed chemical composition of the oil or based on total hydrocarbon concentration (THC) and dispersed oil in the water column. Degradation and toxicity of the oil components can be important to estimate exposure and damage as correct as possible.
For environmental risk analyses
- Varying vulnerability in different geographical areas shall be accounted for in the analyses
- A reference-based analysis may be performed, if updated analyses for a comparable activity in the vicinity, which is based on the best available input data, is available. It should be justified why the environmental risk will be similar or lower than in the reference activity.
- The analyses should give a brief description of the vulnerability of the selected environmental values, their protection status, fraction of a population and seasonal variations. Further, the selection of the environmental values should be justified and the data source should be referred.
- The environmental risk analysis should have a description of which functions that are used to calculate the damage and the degree of seriousness of the damage (the consequence) for the different environmental values. If unpublished damage functions are used, these should be described and justified. Any assumptions made in the estimations, for example based on insufficient knowledge, should be described.
- The analyses should give a balanced and general picture of the environmental risk and give a relevant basis for a decision, according to the first section. For fields with several activities, the risk contribution from each activity/facility (for example pipeline or riser-discharges, drilling operations, production or offloading situations) should be described. For field development and fields in production, changes in the risk level caused by the different activity levels over time, should be described. For exploration drilling, this could be limited to blowouts, but with different contributions from a seafloor or surface blowout.
- The results from the analyses should have a sufficient resolution and be presented on a monthly or seasonal basis. It should be possible to compare the environmental risk for the different facilities.
- The risk contribution from the different facilities and activities should be seen in context according to the first section, first sentence. Unmanned facilities should be seen in context with the manned facility it is connected to.
For environmental emergency preparedness analyses
- The operator should set goals for reduction of the environmental risk, including goals for protecting the vulnerable environmental values, prior to the emergency preparedness analysis. The analyses should also cover minor discharge incidents and measures to limit and combat these according to Section 7 of the Management regulations.
- The selection of dimensioning incidents should be performed so that a sufficient part of the rate/duration distribution is covered and that no scenarios with a large rate and/or long duration with a significant probability is excluded. The operator must make a judgement on this, reviewing that the contingency shall be dimensioned in accordance to the risk.
- The emergency preparedness analysis shall result in a description of the contingency requirements in all barriers, according to Section 73 of the Activities Regulations. The contingency requirements in the different barriers should be calculated based on statistical simulations of drift and dispersion. The expected weathering and amount of emulsion into each barrier should be specified.
- As a part of the emergency preparedness analysis, damage calculations with different response alternatives, or an assessment or calculation of risk reduction showing the effect of the risk reducing measures, should be described. If the combination of presence of vulnerable environmental values and whether reduced accessibility/remoteness creates additional challenges for the preparedness, this should be described in the analysis.
Onshore petroleum activities
The following principles should be considered when carrying out environmental risk and emergency preparedness analyses for onshore facilities:
- The responsible party should set goals for protection of prioritised, vulnerable environmental values. Before the analysis is carried out, various equipment alternatives and their availability shall be mapped. The analysis shall include the categories sea surface, water column and coast and shoreline, and it shall ensure that the varying vulnerability in the different geographical areas is accounted for.
- The risk analyses should use the incident sequences that can result in acute pollution. The initiating incidents should be ranked, i.a. using analyses of drift and dispersion. The incident sequences should if necessary be supplemented with other types of incidents and conditions that can also result in acute pollution.
- A rate/duration distribution shall be established for the identified discharge incidents. The incidents shall be analysed using analyses of drift and dispersion which include the rate/duration distribution. The analyses of drift and dispersion shall be carried out so that they cover the time periods when the ecosystems or specially selected elements in the ecosystems are most vulnerable to acute pollution.
- The requirement for viewing risk contribution in context as mentioned in Section 11 of the Framework Regulations, entails that the result of the risk analysis shall have sufficient detail and be presented in comparable categories.
Important information for conducting environmental risk analyses includes:
- the land facility’s discharge potential,
- likelihood of discharges from various facilities and different risky operations,
- the physical, chemical and ecotoxicological properties of the pollution,
- meteorological and oceanographical data on wind, temperature and current,
- the drift and dispersion of the pollution,
- the weathering and degradation of the pollution,
- vulnerability of the ecosystems,
- environmental databases and environmental prioritisation maps covering vulnerable and prioritised environmental values and their extent in time and space.
Safeguarding particularly vulnerable environmental values shall be highlighted in the environmental risk and emergency preparedness analyses.